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Closed Captioning Best Practices and Legal Requirements Digital Distribution of TV & Film

April 17, 2014

Sean Bersell

Entertainment

Merchants Assoc.

Claudia Rocha

3Play Media

Josh Miller

3Play Media

Dae Kim

Netflix

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Agenda

‣ Captioning overview (Josh Miller)

‣ Legal update (Josh Miller)

‣ EMA best practices (Sean Bersell)

– Certifications, formats, frame rates

‣ 3Play Media best practices (Claudia Rocha)

– Standards for transcription + captioning

‣ Netflix best practices (Dae Kim)

– Styling, onscreen placement, delivery, encoding

‣ Industry trends (Dae Kim)

‣ Q&A

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What Are Closed Captions?

‣ Text that has been time-synchronized with the media

‣ Captions convey all spoken content as well as relevant sound effects

‣ Originated in the early 1980s from an FCC mandate for broadcast TV

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Closed Captioning Terminology

Terminology

‣ Captioning vs. Transcription

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Closed Captioning Terminology

Terminology

‣ Captioning vs. Transcription

‣ Captioning vs. Subtitling

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Closed Captioning Terminology

Terminology

‣ Captioning vs. Transcription

‣ Captioning vs. Subtitling

‣ Closed vs. Open Captioning

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Closed Captioning Terminology

Terminology

‣ Captioning vs. Transcription

‣ Captioning vs. Subtitling

‣ Closed vs. Open Captioning

‣ Post Production vs. Real-Time

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Caption Formats

Format Type Use Cases

SCC Broadcast, iOS, web media

SMPTE-TT Web media

CAP Broadcast

EBU.STL PAL Broadcast (Europe)

SRT YouTube and web media

DFXP Flash players

WebVTT Emerging HTML5

SAMI Windows Media

QT QuickTime

STL DVD encoding

CPT.XML Captionate

RT Real Media

SRT Example

01:02:53:14 94ae 94ae 9420 9420

01:02:55:14 942c 942c

01:03:27:29 94ae 94ae 9420 9420 94f2

SCC Example

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Benefits

‣ Accessibility for deaf and hard of hearing

‣ For ESL viewers

‣ Flexibility to view in noise-sensitive environments

‣ Search

‣ Navigation, better UX

‣ SEO/discoverability

‣ Used as source for translation

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Legal UpdateCVAA

‣ Captions required for all Internet content that aired on TV with captions

‣ Does not yet apply to video clips

‣ 13 Exemptions

ADA

‣ Title II: public entities

‣ Title III: commercial entities “places of public accommodation”

‣ Recent case law: – NAD v. Netflix, GLAD v. Time Warner

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CVAA Timeline‣ Phased In: All prerecorded programming that is

not edited for Internet distribution

‣ Phased In: Live & near-live programming originally broadcast on television.

‣ Phased In: Prerecorded programming that is edited for Internet distribution.

‣ Phased In : Archival programming (45 days)

‣ Mar 30, 2015: Archival programming (30 days)

‣ Mar 30, 2016: Archival programming (15 days)

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FCC Standards for Caption Quality ‣ Caption accuracy

– Must match spoken words to fullest extent possible and include verbal

information

– Allows some leniency for live captioning

‣ Caption synchronization– Must coincide with their spoken words and sounds to the greatest extent

possible

‣ Program completeness– Captions must run from the beginning to the end of the program

‣ Onscreen caption placement– Captions should not block other important visual content

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FCC Guidelines for User Control

‣ Took affect January 1, 2014‣ Only applies to online full-length programming that previously appeared

with captions on television in the U.S.‣ VPDs must comply with advanced closed captioning standards CEA-708 ‣ End user control of font type, size, background color, opacity, character

edge style

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FCC Exemptions for Closed Captioning‣ Economically burdensome exemption

– Requires petition

‣ Self-implementing exemption – Programming is in a language other than English or Spanish

– Programming is primarily textual

– Programming is distributed between 2 a.m. and 6 a.m.

– Interstitials, promotional and public service announcements (up to 10 mins)

– EBS (Educational Broadband Service) programming

– Locally produced and distributed non-news programming with no repeat value

– Programming on new networks for the first four years

– Primarily non-vocal musical programming

– Captioning expense in excess of 2% of gross revenues

– Revenues under $3,000,000

– Locally produced educational programming

– Programming is subject to contractual captioning restrictions

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PRESENTATION BY SEAN BERSELL

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Transcription Standards‣ Spelling should be at least 99% accurate.

‣ When multiple speakers are present, sometimes it is helpful to identify who is speaking, especially when the video does not make this clear.

‣ Both upper and lowercase letters should be used.

‣ Non-speech sounds like [MUSIC PLAYING] or [LAUGHTER] should be added in square brackets.

‣ Sound effects that are pertinent to the plot should be included.

‣ Punctuation should be used for maximum clarity.

‣ Captions can be used to preserve and identify slang or accents (preferential)

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Captioning Standards‣ Font style should be non-serif, such as Helvetica medium.

‣ Each caption frame should hold 1 to 3 lines of text onscreen at a time

‣ Each line should not exceed 32 characters.

‣ Minimum viewable duration of 1 second.

‣ Extended sound effects (like [MUSIC]) should drop off the screen after 4 to 5 seconds

‣ Each caption frame should be replaced by another caption (unless there’s a long period of silence).

‣ All caption frames should be precisely time-synched to the audio.

‣ A caption frame should be repositioned if it obscures onscreen text or other essential visual elements.

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PRESENTATION BY DAE KIM

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QUESTIONS?

ResourcesEMA Best Practices on Closed Captioning: http://www.entmerch.org/digitalema/committeescouncils/closed-captioning-committee/

CVAA Captioning Requirements: http://info.3playmedia.com/wp-cvaa.html

How the ADA Impacts Captioning: http://info.3playmedia.com/wp-ada.html

FCC Ruling 2/20/2014: http://www.fcc.gov/document/closed-captioning-quality-report-and-order-declaratory-ruling-fnprm